412.09 (06/03/2009 – Rev.

11)
Identifier: PRD-2105
HEAVY METALS Revision*: 5
Page: 1 of 6
Program Requirements For Additional Info:
Subcontractors Effective Date: 01/04/17
Document http://EDMS
Manual: Subcontractor Requirements - Change Number: 351737
*The current revision can be verified on EDMS. Alternate ID: SRM-ISIH-2.16

1. PURPOSE
This document provides requirements for the implementation of controls for work with
and around heavy metals (see def.), as listed below in Section 3, to ensure worker safety
and health. This document lists requirements from codes and standards along with
contractor (see def.) requirements. Any applicable regulatory or contractor requirements
must be followed, with the most stringent requirement being met.

2. APPLICABILITY
This document applies to all subcontractors working at the Idaho Cleanup Project (ICP)
who perform work with or around heavy metals, as specified in their contract with
contractor. Stricter requirements may be imposed by subcontractors upon their employees
or subtier contractors. The requirements of this document must be followed by
subcontractors; however, the means of implementation may vary as determined by the
subcontractor.

3. REQUIREMENTS
3.1 Code and Standard Requirements

3.1.1 Specific requirements for working with heavy metals are listed in codes
and standards as listed in Section 3.1.2. The requirements listed in this
document are not intended to replace the codes and standards;
requirements listed in each code and standard must be met.

3.1.2 The heavy metal codes and standards are:

29 CFR 1910.1025, “Lead”

29 CFR 1926.62, “Lead”
29 CFR 1910.1018, “Inorganic Arsenic”
29 CFR 1910.1027, “Cadmium”
29 CFR 1926.1127, “Cadmium”
29 CFR 1910.1026, “Chromium (VI)”
10 CFR 850, “Beryllium Rule” (U.S. Dept. of Energy)
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Identifier: PRD-2105
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3.2 General Requirements

3.2.1 A competent person (see def.) shall be assigned to monitor work in

compliance with this document.

3.2.2 Personnel who will be assigned to work with heavy metals shall be
trained to the appropriate level before performing work (see
Appendix A, Training Requirements).

3.2.3 Personnel working with heavy metals or who may be exposed on any
day at or above the action level (see def.) shall participate in a baseline
medical surveillance program before initial assignment.

3.3 Exposure Assessment and Monitoring

3.3.1 Initial exposure assessments shall be performed for employees who work
with or may be exposed to heavy metals per PRD-2111, “Exposure
Assessments.”

3.3.2 Affected employees or designated representatives shall be allowed to

observe any monitoring of employee exposure.

3.3.2.1 Observers shall be provided with appropriate personal

protective equipment, training and medical surveillance
when observation of monitoring requires entry into a
regulated area.

3.3.2.2 Observers shall be provided with the following information:

A. Relevant safety and health requirements

B. An explanation of the measurement procedures

C. An opportunity to observe all steps related to the

monitoring process at the place of exposure

D. A record of the results obtained or copies of the

results when returned by the laboratory.

3.4 Work Control

3.4.1 Controls shall be implemented using the hierarchy of controls,

i.e., engineering, administrative and personal protective equipment,
respectively.

3.4.2 Ventilation systems shall be provided when feasible.

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Identifier: PRD-2105
HEAVY METALS Revision*: 5
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3.4.3 Employees shall use engineering controls provided and shall report any
problems with the engineering controls to their supervisor.

3.4.4 Administrative controls shall be implemented, but not allow use of

employee rotation as a means to reduce exposure.

3.4.5 When airborne concentrations exceed the permissible exposure limit

(PEL) during a work activity, written documents meeting the
requirements of a compliance plan required by the codes listed in
Section 3.1, shall be provided, this may include using any of the
following:

A. Work order
B. Approved procedure
C. Exposure assessment
D. Job safety analysis
E. Any other hazard evaluation.

3.5 Respiratory Protection

3.5.1 Respiratory protection shall be in accordance with 29 CFR 1910.134,

with the protection factors invoked by specific requirements for the
heavy metal.

3.5.2 When necessary, the appropriate level of respiratory protection shall be

selected in accordance with PRD-2109, “Respiratory Protection,” and the
specific codes and standards for each heavy metal.

3.6 Protective Work Clothing and Equipment

3.6.1 Protective clothing shall be provided and maintained.

3.6.2 Employees shall wear protective clothing and shall use protective
equipment as required by work documentation.

3.6.3 Contaminated protective clothing and equipment shall be disposed of in

designated, labeled containers.

3.7 Housekeeping

3.7.1 Housekeeping methods shall be conducted to minimize exposures.

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Identifier: PRD-2105
HEAVY METALS Revision*: 5
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3.8 Hygiene Practices

3.8.1 Hygiene practices shall be followed to reduce exposures and eliminate

contamination from leaving the work area.

3.9 Medical Surveillance and Medical Removal Protection

3.9.1 The subcontractor’s occupational medical program shall provide for

medical surveillance in accordance with specific heavy metal
requirements listed in Section 3.1, except that Beryllium medical
surveillance shall be provided at the contractor’s medical facility.

3.9.2 Employees occupationally exposed to heavy metals may participate in

the medical surveillance program as provided for in the requirements
listed in Section 3.1.

3.10 Labels and Signs

3.10.1 The appropriate signs and labels shall be provided at work areas,
regulated areas, and disposal containers.

4. DEFINITIONS
See LST-27, “Glossary”

5. REFERENCES
5.1 Source Documents

29 CFR 1910.1025, “Lead”

29 CFR 1926.62, “Lead”

29 CFR 1910.1018, “Inorganic Arsenic”

29 CFR 1926.1118, “Inorganic Arsenic”

29 CFR 1910.1027, “Cadmium”

29 CFR 1926.1127, “Cadmium”

29 CFR 1910.1026. “Chromium”

29 CFR 1926.1126, “Chromium”

40 CFR 850 Beryllium Rule (Dept. of Energy)

PRD-2030, “Occupational Medicine”

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5.2 Related Requirements

The following documents may also contain requirements that apply to this
activity:
PRD-2022, “Safety Signs, Color Codes and Barriers”

PRD-2101, “Hazard Communication”

PRD-2109, “Respiratory Protection”

6. APPENDIXES
Appendix A, Training Requirements

HEAVY METALS
Training requirements for employees occupationally exposed to heavy metal.
Level of Exposure
Incidental, works with solids, or Awareness Training, or
Exposure < action level on any
day
Exposure > action level on any
day,
412.09 (06/03/2009 – Rev. 11)
Identifier: PRD-2105
Revision*: 5
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Appendix A
Training Requirements
Training Required Frequency
Initial (before job
assignment);
29 CFR 1910.1200 or 1926.59,
“Hazard Communication“; and When work coordinator, job
supervisor, or competent
As referenced in applicable code
person determines that
and standard.
retraining or additional
training is necessary.
Comprehensive Training Initial (before job
assignment); and annually,
As referenced in applicable code
or as required by the
and procedure;
applicable standard.
Specific nature of operations
which could result in exposure to
heavy metal above the action level;
Purpose, proper selection, fitting,
use, and limitations of respirators;
Purpose and description of medical
surveillance program;
Engineering controls and work
practices;
Associated contractor procedures;
Information on chelating agents;
Information on employee's right of
access to records.
Appendix A